{In Archive} Draft - Title V response j ennifer.wilder to: Shaheerah Fateen 05/25/2004 12:58 PM

From: j ennife r .wilder@exxonmobil.com

To: Shaheerah Fateen/R9/USEPA/US@EPA,

Archive: This message is being viewed in an archive.

Shaheerah Here is a copy of the letter that will go out today. It does not have any of the back up information, but I have copied you on

the letter to Mr. Rios, so hopefully you will receive that soon. If you have any questions, please don't hesitate to

e-mail or call me. Thank you for your patience with this (See attached file: Title V EPA response_May 25.doc)

Jennifer Wilder Baird Compliance Engineer ExxonMobil Production Company Office: (281) 654-1135 Fax: (281) 654-1147 jennifer.wilder@exxonmobil.com

Title V EPA response_May 25.docMay 25, 2004

Gerardo C. Rios Chief, Permits Office United States Environmental Protection Agency Region IX

75 Hawthorne Street San Francisco, CA 94105

Subject: Response to Request for Information to Update Part 71 Permit Application No. NN-OP 00-07

Dear Mr. Rios:

ExxonMobil submits this letter in response to Region IX's letter dated March 31, 2004. In order to respond to the request it is important to review a brief history of ExxonMobil's McElmo Creek Unit (MCU) site. The original PSD permit included several pieces of equipment as listed in your Attachment A; however, during the middle of the 1990s the NGL f acilities were shut down due to economic. With the shut down of the NGL process, all gas driven compressors and turbines within the plant were converted to electric, sulfur recovery was ceased and gas dehydration was reduced. Today ExxonMobil's MCU site contains only the follo wing air emitting sources: emergency/process flare, gasoline tank, TEG reboiler, Glycol heater. The line heater (also know as CO2 heater) was removed on March 8, 2004.

Below are ExxonMobil's responses to each of th e items addressed in Region IX's letter:

1. The gas turbine, T4500 was removed June 1998; therefore, 40 CFR part 60 Subpart GG is not applicable.

2. The McElmo facility no longer processes natural gas liquids. This process was discontinued and

dismantled in June 1998. Therefore 40 CFR Part 60 Subpart KKK is no longer applicable.

3. The McElmo facility is not classified as a natural g as processing facility. In addition, the plant does

not sweeten or recover sulfur. This declassifica tion and removal of sulf ur recovery equipment

occurred in June 1998. Therefore 40 CFR Part 60 Subpart LLL is no longer applicable.

4. Currently only one TEG reboiler is in operation at the McElmo Creek Unit. The emissions from the

still vent are routed to the flare to control a nd reduce emissions. Subpart HH MACT standard does not apply because emissions are low enough that they do not trigger the regulation. Attached In are current emissions as calculated by GRI-GLYCalc. In addition, last years emission inventory is included for your reference.

5. As describe above, all equipment except one TEG reboiler has been removed from ExxonMobil's MCU site. The removal of the equipment was comple ted in June 1998. Attached for your referenceis a copy of our historic AFE documentation that lists the project year, the project description and gives a break down of the cost.

6. Benzene is present at the MCU site, however no stream contains or contacts benzene greater than 10 percent by weight. In 2001 liquid and gas samples were taken and analyzed. Benzene was present in the plant closed drain system and in the inlet gas st ream. On a volume percent basis, the liquids in the closed drain system contained 0.3839 percent ben zene while the inlet gas sample contained 0.0279 percent. For a more recent inlet gas analysis please see the attached GRI-GLYCalc calculation.

Currently, ExxonMobil is in negotiations with the De partment of Justice and the EPA for a consent decree at the MCU site. It is important to note that the Consent Decree has several stipulations that must be carried over into the Title V and PSD permit. These include permit limits, monitoring, operation and maintenance plans and semi annual reporting. Also, as part of the PSD permit, ExxonMobil must conduct a BACT analysis and air quality analysis. Exxo nMobil would like to discuss these terms and conditions

with the Permit Office. Jennifer Wilder Baird will contact Shaheerah Fateen within the next several

weeks to discuss further.

If you have any further questions, please contact Jennife r Wilder Baird by phone at (281) 654-1135 or via e-mail at jennifer.wilder@exxonmobil.com.

Yours truly,

Neil J Ryan Regulatory Compliance Supervisor ExxonMobil Production Company

Attachments

CERTIFIED MAIL RETURN RECEIPT REQUESTED

CC: Shaheerah Fateen, EPA Region IX

75 Hawthorne Street San Francisco, CA 94105Bc: Arlene Lee Delphine Whitehorse

Joel Talavera Neil J Ryan

Jennifer Wilder Baird

CORP-MI-PO20D

## Emissions from TEG System

GRI GLYCalc

## AFE Documentation